Code of Ethics

Revision Date: June 28, 2021

Purpose of the Policy:  The values of The Pew Charitable Trusts are described in this Code of Ethics and implemented through Pew’s internal policies and practices. These values and the institution's commitment to the public interest inform and guide the actions of our board and staff.

Personal and Professional Integrity

The board (including emeritus directors) and staff of Pew act with honesty, integrity and openness in all their dealings on behalf of Pew. Pew promotes a working environment that values respect, fairness and the highest professionalism. This commitment requires that all violations of applicable laws and Pew policies be immediately reported in accordance with Pew’s Whistleblower policy (for more read “The Pew Charitable Trusts Whistleblower policy”).

Mission

Pew has a clearly stated purpose, approved by its board of directors, to:

• Improve public policy by conducting rigorous analysis, linking diverse interests to pursue common cause and insisting on tangible results;
• Inform the public by providing useful data that illuminate the issues and trends shaping our world;
• Invigorate civic life by encouraging democratic participation and strong communities. In our hometown of Philadelphia, we support arts and culture organizations as well as institutions that enhance the well-being of the region’s neediest citizens.

Governance

Pew has a governing board of directors that is responsible for setting the mission and strategic direction of Pew, as well as oversight of the policies, programs, finances and operations of Pew. Pew’s board works to ensure that:

• Its board members have the requisite skills and experience to carry out their duties and that all directors understand and fulfill their responsibilities for the benefit of Pew and its public purposes;
• Any conflicts of interest or the appearance thereof are avoided or appropriately managed through disclosure, recusal or other means pursuant to Pew's bylaws and its conflict of interest, financial interest disclosure, and anti-nepotism policies;
• Any conflicts of interest or the appearance thereof are avoided or appropriately managed through disclosure, recusal or other means pursuant to Pew's bylaws and its conflict of interest, financial interest disclosure, and anti-nepotism policies;
• Pew’s board is responsible for the hiring, firing and annual review of the performance of the CEO, including setting compensation;
• the CEO and appropriate staff provide the Pew board with timely and comprehensive information so that the governing body can effectively carry out its duties;
• Pew conducts all transactions and dealings with integrity and honesty;
• Pew promotes working relationships with board members, staff, donors, grantees and constituents that are based on mutual respect, fairness and openness;
• Pew is fair and inclusive in its hiring and promotion policies and practices for all staff positions;
• Pew policies are in writing, clearly articulated and properly adopted;
• Pew resources are responsibly and prudently managed; and
• Pew has the capacity to carry out its mission effectively.

Responsible Stewardship

Pew manages funds responsibly and prudently by:

• Spending a high percentage of its annual budget on programs that further the organization's mission;
• Spending an adequate amount on administrative expenses to ensure effective accounting systems, internal controls, competent staff and other expenditures critical to professional management;
• Compensating staff, and any others who may receive compensation, reasonably and appropriately;
• Maintaining appropriate operating revenues;
• Respecting donor intent;
• Working to ensure that all spending practices and policies are fair, reasonable and appropriate to fulfill the mission of Pew;
• Ensuring that financial reports are accurate and complete in all material respects; and
• Obtaining an annual third-party audit by a certified public accounting firm.

Disclosure

Pew provides detailed information to the public, the media and all stakeholders, and responds in a timely manner to all reasonable requests, including requests for the three most recent Form 990 information tax returns and requests for the audited financial statements. Information made available by Pew accurately reflects the policies and practices of the organization. All financial, organizational, and program reports are complete and accurate in all material respects.

Program Evaluation

Pew regularly reviews program effectiveness and has mechanisms to incorporate lessons learned into future initiatives. Pew is committed to improving program and organizational effectiveness and develops mechanisms to promote learning from its activities.

Nondiscrimination and Inclusiveness

Pew has a policy of nondiscrimination and promotes inclusiveness. Pew forbids discrimination based on gender, race, color, creed, religion, national origin, ancestry, citizenship, age, sexual orientation, gender identity or expression, personal appearance, political affiliation, marital status, familial status, genetic information, pregnancy, childbirth and related medical conditions, breastfeeding, veteran status, military status, matriculation (i.e. being enrolled in or planning to enroll in a college, university, or other secondary school), physical or mental disability, medical condition, denial of medical and family care leave or pregnancy disability leave, protesting illegal discrimination, and/or any other characteristic protected by laws and regulations in the applicable jurisdiction (collectively “Protected Characteristics”) and takes meaningful steps to promote inclusiveness in the recruitment, hiring, retention and promotion of staff.

Fundraising

Any fundraising materials of Pew, and any communications with donors and potential donors, are truthful and accurate. Pew respects the privacy concerns of donors and expends funds consistent with donor intent. Pew discloses important and relevant information to donors and potential donors. In raising funds from the public, Pew respects the rights of donors to:

• Be informed of the mission of Pew, the way resources will be used and Pew's capacity to use contributions effectively for their intended purposes;
• Be informed of the identity of those serving on Pew's governing board and to expect the board to exercise prudent judgment in its responsibilities;
• Have access to Pew's most recent audited financial statements and Form 990 information returns;
• Be assured their gifts will be used for the purposes for which they were given;
• Receive appropriate acknowledgement and recognition;
• Have their anonymity preserved if requested, to the extent permitted by applicable law; and
• Expect that all relationships with individuals representing Pew will be characterized by the highest professionalism.

Grantmaking

As an institution that makes grants, Pew assumes the following additional responsibilities in carrying out its charitable mission. Pew endeavors to:

• Foster constructive relations with grantees based on mutual respect and shared goals;
• Communicate clearly and on a timely basis with current and prospective grantees; and
• Treat current and prospective grantees fairly and with respect.

Legal Compliance

Pew is committed to conducting business legally and ethically and requires its staff to comply with applicable laws and regulations.

Conclusion

This Code of Ethics is, by necessity, general in outlining broad ethical principles for Pew. Pew will be guided by it as well as by other relevant standards for the charitable sector when responding to specific issues not explicitly mentioned above. Questions about the policy can be addressed to Pew’s Senior Vice President, General Counsel and Corporate Secretary.

Designated Policy Contact: The following individual should be contacted for interpretations, resolution of problems, and special situations.
Department: Legal Affairs  Title: Senior Director, Compliance, Legal Affairs